CMS finalized Caregiver Training Services reimbursement for 2024 in the Physician Fee Schedule Final Rule, to be published on Nov 16. There were a few changes and clarifications from the proposed rule in July. A summary of the original proposed rule is here.
Key changes & clarifications on Caregiver Training Services ("CTS"):
- Telehealth: CMS confirmed that CTS will not be added to the telehealth list at this time but will be a consideration for future rulemaking
- Quantity limits: CMS removed quantity limits for CTS. They determined that volume and frequency can be based on the treatment plan and can be provided to multiple caregivers. Documentation of why each CTS occurrence is reasonable and necessary is required in the EMR
- Codes: The specific codes were identified for caregiver training for people needing functional support: 97550, 97551, and 97552
- No required curriculum guidance: CMS did not include specific curriculum, quality, or training requirements but will consider them for future rule-making
- Caregiver definition: CMS clarified their definition of a caregiver that would qualify for CTS. They adopted a definition from the RAISE Family Caregiver Act and CMS Outreach and Education. This approach keeps "unpaid assistance" in the definition
Most of the proposed rule stayed the same, including the RVU reimbursement amounts, the broad set of conditions that CTS can be provided for, the need to link it to a treatment plan, the qualifying practitioners (including PT/OT/ST, nurses, psychologists, physicians), and the requirement to record consent and need in the EMR (more here).
A recap of the codes and their RVU amounts are below: